RE>>Chile 8/21/97
Lisa, You represent Management. Ship/No Ship decisions can be your call. From my position, the options are pretty clear based on my reasoning stated in my e-mail to you. Regards, Tony -------------------------------------- List-Post: [email protected] Date: 8/19/97 6:13 PM To: Tony Fredriksson From: Lisa Eirich Tony- Perhaps there was a level of detail that I missed on that email (it was very old). With regard to your comment on the subject of ship/no ship decisions. This is to confirm what we talked about today. Agency compliance could be in a position to indicate whether or not we are homologated and whether or not we believe that there are homolgation requirements. It is likely that I will be in a position to make the recommendations to ship or not ship. I always copy my manager on the decision. The ship/no ship decision can be reversed. If you can provide me with an assessment (even verbally) of the possible risk, a decision will be made and appropriate personnel will be notified. Thank you for your concern, respond if necessary, Lisa -------------------------------------- List-Post: [email protected] Date: 8/18/97 11:36 AM To: Lisa Eirich From: Tony Fredriksson Lisa, See the attached e-mail below in which you commented on homologations requirements for Chile. I believe that you may have misinterpreted what these sentences say: 1. The first sentence says that safety approvals are required in Chile. 2. The second sentence says that while it is not required for a Chilean based Corporation to request and hold the safety approvals, it is recommended. This does not mean that no one is required to get a safety certificate. If the Chilean based corporation does not hold the certificate, then the inproter or manufacturer would need to. These sentences, while poorly written, are NOT in conflict whatsoever. Secondly, I don't think Agency Compliance' policy should be to recommend shipment unless we know there are homologation requirements. Our policy should be to recommend AGAINST shipment unless we know there ARE NOT homologations requirements. The only exception should be if the distributor or customer puts in writing that they will assume all responsibility for homologation of our equipment if homologation is found to be needed after the customer takes delivery of the equipment. The fact that NTUs and INTUs are up and running in a country says little about the requirements for homologations. It could be that a country has little or no enforcement of their own regulations. The equipment may be illegally deployed, but no one gets caught. The conclusion is analgous to one driving around all the time without your seatbelt on, not getting caught, and assuming there is no seat belt law--flawed logic. I think we need 3 categories in the HDB: 1. Homologation Required (HR) 2. Homologation Not Required (HNR) for those countries where we KNOW from reliable sources that it is not required. 3. Homologation Not Determined (HND) for those countries where we are not sure, such as Chile. Again, or HND we should not recommend shipment unless the we get it in writing from the distributor or customer that they do not require it for their use of the product. Regards, Tony ************************************************* List-Post: [email protected] Date: 5/8/96 2:33 PM From: Lisa Eirich I think that it is great that we have INTUs in Chile! They are up and running and haven't been shut down (or we'd hear about it). Here is what the person said: "Product Safety Testing: Testing in labs in Chile is required. While not required, it is recommended that a Chilean Corporation request and hold Safety Certificate." In a matter of the first two sentences, they are in direct conflict. We should continue to assume NHR for Chile until we KNOW otherwise. Obviously this person doesn't KNOW. Lisa -------------------------------------- List-Post: [email protected] Date: 5/8/96 1:32 PM To: Lisa Eirich From: Kamran Mohajer Lisa, What do you think of this. We have INTUs and NTUs in Chile now! Kamran -------------------------------------- List-Post: [email protected] Date: 5/8/96 11:56 AM From: [email protected] REGARDING Regulatory Approvals for Chile From: Kaz Gawrzyjal-ESN... All, My thanks to all who have responded with answers; to my inquiry on regulatory approval requirements for market access into Chile. The following is a summary of the response: (Thanks Lori Wilson) Summary: Products can be imported without restrictions as there are no formal import restrictions. For products in question since Homologation is required and safety testing must be done before submitting for homologation,all is required. Product Safety Testing: Testing in labs in Chile is required. While not required, it is recommended that a Chilean Corporation request and hold Safety Certificate. Import Restrictions: Again there are none. Telecommunications: Homologation required. Testing/Review for all products that will connect to national phone network. Specific Regulations for Satellite Receivers: Conditional, In process. Key Agencies: CENET=CHILE-TELEPHONE/REGULATORY AGENCY CEO Mr. Jonny Wolf Address: Anturo Prat 1171 of 304 Saniago Chile 562-556-1535 Home Phone Connections: Standard connection is RS-11. In very limited amounts, other older types are also present. The Compliance Process: Chile has regulations requiring testing and certification. 1) Product Safety - Chile recognizes Safety Certification from other countries, as the basis for their approval. The products are required to be processed/tested in Chile. Our team in Chile reports that enforcement of the regulations is very lax. 1A) Documentation - The following is required for Product Safety submission to a Lab in Chile. A) A Spanish Language Owners/Users Manual and B) Power Supply Schematics. Recommended additional Documentation: ETL,UL,etc. Listing Letter and two (2) samples to be submitted. Timing for the typical product safety test for electronic products requires two/three weeks. 2) Certification of Testing - Only Chilean Corporations may apply for and receive Certificates. Certificates are issued by CENET (Takes 2 to 4 weeks.) They (CENET) will also require a submittal of the Manufacturer's Declaration of Quality, in Spanish. 3) Telecommunications (Homologation) Approval: A) Review/Testing - Any product that will connect to the National Phone System or use radio frequencies must be submitted for Evaluation/Testing and Licensing by the CENET. All products submitted for Evaluation/Testing must first be approved for Product Safety. Telecommunications products with FCC Part 68 approval may be submitted for Review with three (3) copies of the FCC Part 68 report (required to enter the Review Process). Products are also to submitted to the examiner. This review takes about two (2) to four (4) weeks. After this is completed the Review Report or Lab Report is submitted to CENET with an application for License. This takes approximately 20 working days from the receipt of documents for the File Number/Certificate/ 4) General Comment - Chile is a "free" market, but has a political content beyond the Certification process. Concessions have been granted to private companies to operate cable and cellular systems in Chile. Depending on the company that introduces the product into the Chilean Market, there is a potential for "Administrative Review" before Certification may be obtained. And yet another question. Does Chile require any power factor correction on equipment tied into the power grid? Is there a specification.? David? Regards, Kaz Gawrzyjal Nortel-Safety Eng. [email protected] ------------------ RFC822 Header Follows ------------------ Received: by Mac2.net.com with SMTP;8 May 1996 11:55:38 -0800 Received: from europe.std.com by unet.net.com (SMI-8.6/SMI-SVR4) id LAA01314; Wed, 8 May 1996 11:52:13 -0700 Received: by europe.std.com (8.7.5/BZS-8-1.0) id OAA21529; Wed, 8 May 1996 14:12:27 -0400 (EDT) X-Authentication-Warning: europe.std.com: daemon set sender to treg-approval using -f Received: from world.std.com by europe.std.com (8.7.5/BZS-8-1.0) id OAA21525; Wed, 8 May 1996 14:12:25 -0400 (EDT) Received: from corpgate.rich.nt.com (corpgate.nt.com) by world.std.com (5.65c/Spike-2.0) id AA25354; Wed, 8 May 1996 14:09:29 -0400 Received: from nrchh57.rich1.nt.com by corpgate.rich.nt.com with SMTP (PP); Wed, 8 May 1996 15:44:42 +0000 Received: from nmiss1.miss.nt.com by nrchh57.rich1.nt.com with SMTP (1.38.193.5/16.2) id AA01777; Wed, 8 May 1996 10:27:45 -0500 Message-Id: <[email protected]> List-Post: [email protected] Date: 8 May 1996 09:21:44 -0400 From: Kazimier Gawrzyjal <[email protected]> Subject: Regulatory Approvals for Ch To: EMC PSTC <[email protected]>, [email protected] X-Mailer: Mail*Link SMTP-QM 3.0.2 Mime-Version: 1.0 Content-Type: text/plain; charset="US-ASCII"; Name="Message Body" Content-Transfer-Encoding: quoted-printable Sender: [email protected] Precedence: bulk Reply-To: [email protected]
